MFA submitted comments to ESMA on its consultation on possible implementing measures of the Alternative Investment Fund Managers Directive (AIFMD). In our response, we encouraged ESMA to: (1) narrow the definition of assets under management to better focus the scope of the AIFMD on those managers and funds that should be of greatest regulatory focus for EU regulators; (2) provide greater flexibility in the methods by which managers calculate leverage; (3) ensure that the rules relating to depositaries do not unintentionally create concentration of risk or overly burdensome costs for fund managers; and (4) avoid imposing requirements on third country managers marketing under national private placement regimes that go beyond the requirements specified in the AIFMD.